P°ST< RECEIVED 17 North Second Street 12th Floor Harrisburg, PA 17101-1601 ^SCHELLJtC 2115DEC 30 AHIh 22 717-731-1970 Main ATTORNEYS AT LAW 717-731-1985 Main Fax PA PUC www.postschell.com SECRETARY'S OLiREAU FROM!DESK Anthony 0. Kanagy [email protected] 717-612-6034 Direct 717-720-5387 Direct Fax' - File #: 178835 December 30,2019 VIA HAND DELIVERY Rosemary Chiavetta, Secretary Pennsylvania Public Utility Commission Commonwealth Keystone Building 400 North Street, 2nd Floor North *1 2 3 P.O. Box 3265 Harrisburg, PA 17105-3265 Re: Application of Duquesne Light Company Filed Pursuant to 52 Pa. Code Chapter 57, Subchapter G, for Approval of the Siting and Construction of the Mon-Fayette Tower Relocations Project in West Mifflin Borough, Borough of Dravosburg, and the City of Duquesne in Allegheny County, Pennsylvania Docket No. A-2019- • Dear Secretary Chiavetta: Enclosed, for filing on behalf of Duquesne Light Company, are the following: 1. Original of the Application and the Attachments in support of the Application; 2. Direct Testimony in support of the Application, which are contained in a separately-bound volume; and 3. A CD containing copies of the Application, Exhibits, Attachments, and Direct Testimony. Also enclosed is a check in the amount of $350 for payment of the filing fee. Copies of the Application and accompanying Attachments, and Direct Testimony are being served by certified mail, return receipt requested upon the parties indicated on the certificate of service. Subject to Commission approval, construction is scheduled to begin July 2021 to meet an in- service date of March 2023. Allentown Har r isbur g Lancast er Philadel phia Pit t sbur g h Princeton Washingt on, D.C. A Pennsyl vania Professional Cor poration 1963l720vl Rosemary Chiavetta, Secretary December 30,2019 Page 2 If there are any questions concerning this matter, please contact me at the addresses or telephone numbers provided above. ADK/jl Enclosures cc: Certificate of Service Renardo L. Hicks Paul T. Diskin Jordan Van Order Kimberly Hafher 19631720vl BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION Application of Duquesne Light Company : filed Pursuant to 52 Pa. Code Chapter 57, : Subchapter G, for Approval of the Siting and : Docket No. A-2019-__________ Construction of the Mon-Fayette Tower : Relocations Project in West Mifflin : Borough, Borough of Dravosburg, and the : City of Duquesne in Allegheny County, : Pennsylvania : ________________________________________________ APPLICATION OF DUQUESNE LIGHT COMPANY ________________________________________________ TO THE PENNSYLVANIA PUBLIC UTILITY COMMISSION: Duquesne Light Company (“Duquesne Light” or the “Company”) hereby files, pursuant to 52 Pa. Code § 57.72, this Application requesting Pennsylvania Public Utility Commission (“Commission”) approval to relocate portions of existing overhead 138 kV transmission lines. The Pennsylvania Turnpike Commission (“PTC”) is designing and constructing a highway extension, to extend the Mon-Fayette Expressway (“MFE”) from PA Route 51 in Jefferson Hills Borough to the Monongahela River in the City of Duquesne. This section is known as the PTC’s Southern Section of the MFE Project. Construction of the highway expressway will include substantial grading, construction of bridges, development of drainage and storm water management features, and a significant number of utility relocations. A portion of those utility relocations includes Duquesne Light electric transmission lines. Through this Application, Duquesne Light seeks Commission approval of the siting and construction of the proposed Mon-Fayette Expressway Tower Relocation Project (the “Project”). Subject to the Commission’s approval, the Project has a scheduled construction start date of July 19637745v4 2021 to meet an in-service date of March 2023. In support of this application, Duquesne Light states as follows: I. INTRODUCTION 1. This application is filed by Duquesne Light, a public utility that provides electric distribution, transmission, and provider of last resort services in Pennsylvania subject to the regulatory jurisdiction of the Commission. 2. Duquesne Light’s principal business address is: Duquesne Light Company 2825 Beaver Avenue Pittsburgh, PA 15233 3. Duquesne Light’s attorneys are: Michael Zimmerman (PA ID # 323715) Anthony D. Kanagy (PA ID # 85522) Duquesne Light Company Garrett P. Lent (PA ID # 321566) 411 Seventh Avenue Post & Schell, P.C. Mail Drop 15-7 17 North Second Street Pittsburgh, PA 15219 12th Floor Voice: 412-393-6268 Harrisburg, PA 17101-1601 Email: [email protected] Voice: 717-731-1970 Fax: 717-731-1985 E-mail: [email protected] E-mail: [email protected] Duquesne Light’s attorneys are authorized to receive all notices and communications regarding this Application. 4. Duquesne Light furnishes electric service to approximately 600,000 customers throughout its certificated service territory, which includes all or portions of Allegheny and Beaver Counties and encompasses approximately 800 square miles in western Pennsylvania. Duquesne Light is a “public utility” and an “electric distribution company” as defined in Sections 102 and 2803 of the Pennsylvania Public Utility Code, 66 Pa.C.S. §§ 102, 2803. 2 19637745v4 5. Accompanying this Application is Statement No. 1, the direct testimony of Mr. Nicholas Anderson to provide a summary of the Project schedule and public outreach; Statement No. 2, the direct testimony of Ms. Sarah Soard related to the Siting Study; Statement No. 3, the direct testimony of Ms. Meenah Shyu related to Project need, design, and safety; and Statement No. 4, the direct testimony of Ms. Lesley Gannon related to Right-of-Way for the Project. Additionally, the following Attachments are included that provide additional detailed information regarding the proposed Project: • Attachment 1 – PUC Cross-Reference Matrix • Attachment 2 – Need Statement • Attachment 3 – Cross-Sectional Diagrams of Typical Structures • Attachment 4 – Environmental Assessment and Line Route Siting Study • Attachment 5 – Data Sources Reviewed for Environmental Assessment and Line Route Siting Study • Attachment 6 – Aerial Map of Alternatives Considered • Attachment 7 – Topographical Map of Alternatives Considered • Attachment 8 – Permit Matrix • Attachment 9 – Map of the Affected Parcels and Landowners • Attachment 10 – Affected Parcels and Landowners Matrix • Attachment 11 – Duquesne Light’s Design Criteria, Electromagnetic Field Practices and Application, and Safety Practices • Attachment 12 – Duquesne Light’s Vegetation Management Practices • Attachment 13 – Public Notices Required by 52 Pa. Code § 69.3102 • Attachment 14 – PTC Summary and Examples of Outreach 3 19637745v4 6. This Application, including the accompanying Attachments and Statements, which are incorporated herein by reference, contains all the information required by 52 Pa. Code §§ 57.72(c), 69.1101, 69.3102 – 69.3107. II. NEED FOR THE PROJECT 7. The Project is required as a result of the PTC’s construction of the MFE, a four- project highway extension. The PTC has completed three MFE projects to date. The remaining MFE project will comprise a four-lane, limited access highway that will connect PA Route 51 in Jefferson Hills, Allegheny County to I-376 in Monroeville, Allegheny County. This MFE project consists of two segments. The next segment of the MFE scheduled for construction beginning in 2021 will run from PA Route 51 in Jefferson Hills to the Monongahela River in the City of Duquesne. 8. This MFE segment interferes with existing utility facilities, including portions of certain Duquesne Light electric transmission facilities in West Mifflin Borough and the City of Duquesne. Duquesne Light must therefore relocate all such facilities in such a manner that they do not interfere with the MFE design or the PTC’s construction activities. 9. Additional information on the need for this Project is included in Attachment 2, Need Statement, and Statement No. 3, direct testimony of Meenah Shyu. III. DESCRIPTION OF THE PROPOSED TRANSMISSION LINE A. OVERVIEW OF THE PROPOSED PROJECT 10. Construction of the MFE will include a significant number of utility relocations, including Duquesne Light transmission lines. Duquesne Light has identified five distinct, largely noncontiguous areas (herein referred to as the “Study Areas”) in which the MFE conflicts with 4 19637745v4 existing Duquesne Light transmission infrastructure. These five areas each require a portion of Duquesne Light’s electric transmission facilities to be relocated to avoid the highway extension. 11. The MFE affects portions of each of the following 138 kilovolts (kV) transmission circuits: • Z-13 Wilson Substation to West Mifflin Substation • Z-14 West Mifflin Substation to Wilson Substation • Z-15 Dravosburg Substation to U.S.S Clariton Substation • Z-57 Universal Substation to U.S.S. Illinois • Z-72 Wilson Substation to Dravosburg Substation • Z-73/Z-74 Dravosburg Substation to West Mifflin Substation • Z-75 Dravosburg Substation to Elrama Substation • Z-76/Z-77 Wilmerding Substation to Dravosburg Substation • Z-78 Logans Ferry Substation to Dravosburg Substation • Z-79 U.S.S. Illinois Substation to Dravosburg Substation • Z-91 Rankin Substation to Dravosburg Substation 12. These existing affected portions constitute approximately 4.4 miles of 138kV overhead transmission lines and 83 supporting structures. They will be replaced with approximately 4.28 miles of relocated 138kV overhead transmission lines supported by 56 new steel structures.